POPIA Compliance Notice

This notice is published by LifeOS AI ("the responsible party"), a company registered in the Republic of South Africa, in accordance with section 18 of the Protection of Personal Information Act 4 of 2013 ("POPIA"). It sets out the purposes for which we process personal information and the rights of data subjects. This notice should be read together with our Privacy Policy.

1. Responsible party and Information Officer

The responsible party for the personal information processed by LifeOS AI is LifeOS AI, a company registered in South Africa. Our Information Officer, responsible for ensuring compliance with POPIA, can be contacted at privacy@lifeos.ai or via our Contact page for any request relating to the processing of your personal information.

2. Categories of personal information processed

• Identification and contact information (name, email address).
• Account and authentication information.
• Profile, assessment, and preference data collected during onboarding.
• Life data you choose to enter (goals, habits, tasks, journal, finance, health, and other entries).
• Usage, device, and analytics data.
• Payment and billing information (processed via our payment partner).

3. Purpose of processing

We process personal information for the following purposes:

• To provide and personalise the Service and the AI Coach.
• To create and manage user accounts and authentication.
• To process payments and administer subscriptions and entitlements.
• To communicate with users about their accounts and the Service.
• To improve, secure, and analyse the Service.
• To comply with legal obligations.

4. Lawful basis and conditions

We process personal information in accordance with the lawful conditions set out in POPIA, including consent, performance of a contract, compliance with a legal obligation, and legitimate interests of the responsible party. We process data only for the purposes for which it was collected, or a compatible purpose, and we ensure processing is adequate, relevant, and not excessive.

5. Recipients and third-party processors

Personal information may be shared with authorised service providers and processors acting on our behalf (such as hosting, analytics, email, and payment partners) under written, POPIA-compliant processing agreements, and where required by law. We do not sell personal information to third parties.

6. Cross-border transfers

Where personal information is transferred to a recipient in a country outside South Africa, we ensure that the transfer is made subject to adequate safeguards and a level of protection consistent with POPIA, in accordance with sections 72 and 73 of the Act.

7. Security safeguards

We implement reasonable technical and organisational security measures to safeguard personal information against loss, unauthorised access, alteration, or disclosure. These include access controls, encryption in transit, and ongoing security review. Should a security compromise occur, we will notify affected data subjects and the Information Regulator as required by POPIA.

8. Retention of personal information

We retain personal information only for as long as is necessary to achieve the purposes for which it was collected or as required by law, after which it is deleted or de-identified in a secure manner.

9. Your rights as a data subject

You have the right to:

• Be informed when your personal information is being processed, as set out in this notice.
• Access the personal information we hold about you.
• Have your personal information corrected where it is inaccurate, incomplete, or out of date.
• Request the deletion of your personal information, where lawful.
• Object to the processing of your personal information under specified circumstances.
• Withdraw consent previously given for processing.
• Lodge a complaint with the Information Regulator regarding the processing of your personal information.

10. Exercising your rights and complaints

To exercise any of the rights above, contact our Information Officer at privacy@lifeos.ai or via our Contact page. We will respond to your request within a reasonable time, and in accordance with POPIA. If you are not satisfied with our response, you may lodge a complaint with the Information Regulator (South Africa) at complaints@inforegulator.org.za or via www.inforegulator.org.za.

11. Changes to this notice

We may update this POPIA Notice from time to time to reflect changes in our practices or the law. Material changes will be communicated via the Service or by email.